TPO held that expenses were incurred by assessee for creating marketing intangibles, which belonged to AE. TPO thus, treated AMP expenses as international transaction and benchmarked same by applying Bright Line test. Tribunal rejected bright line approach and deleted additions made by TPO-It was noted that Tribunal had followed High Court’s decision in Sony Ericsson Mobile Communications India (P) Ltd. v. CIT (2015) 231 Taxman 113/ 374 ITR 118 (Delhi)(HC)  to reject application of bright line test. High Court affirmed the order of the Tribunal.  No substantial question of law. (AY. 2006-07)